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HomeMy WebLinkAbout09-2726fj DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON COMMONWEALTH OF PA, : PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS JULIE RICE, Petitioner NO. 0.,,27?1e PETITION FOR APPEAL OF LICENSE SUSPENSION TO THE HONORABLE, THE JUDGE OF THE SAID COURT: AND NOW, comes Petitioner, Julie Rice, by and through her attorney, Gregory Barton Abeln, Esquire, who files the following petition and represents as follows: 1. The Petitioner, Julie Rice is an adult currently residing at 6 Shenandoah Court, Mechanicsburg, PA 17050. 2. Petitioner is the holder of a valid Pennsylvania Operator's License No. 286399914. 3. The Petitioner's has received a notice of license suspension wherein her license is to be suspended as a result of a violation on February 6, 2009 of violating §6308 (offenses related to alcohol). Attachment "A". 4. The Petitioner has filed an appeal with the Blair County Court of Common Pleas, a copy of which is attached to this petition. Attachment "B" 5. Concurrent with the appeal, Appellant has sent to Penn DOT a request for delay of suspension pursuant to 75 P.S. §1555. 4 WHEREFORE, Appellant requests this Honorable Court to set a time for a hearing on the priority of Appellant's license suspension and immediately stay the imposition of his license suspension pending the result of said hearing. Respectfully Submitted, ABELN LAW OFFI ES DATE: C-+(30[ C_ 5 -- Mft Gregory Barton Abeln, Esquire ID #35960 Attorney for Appellant 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: MAY O1, 2009 JULIE RICE WID D 091146116265a93 001 6 SHENANDOAH CT. PROCESSING DATE 04/24/2009 DRIVER LICENSE 0 26639914 MECHANICSBURG PA 17050 DATE OF BIRTH 12/04/1989 LICENSE IN BUREAU Dear MR. RICE: As a result of your violation an 02/06/2009 of violating Section 6308 (offenses related to alcohol), your driving privilege is being SUSPENDED for a period of 1 YEAR(S) as mandated by section 1532D of the vehicle code. The effective date of suspension is 05/01/2009, 12:01 a.m. This suspension is in addition to any other suspensions al- ready an your record. PROVIDING PROOF OF INSURANCE Within the last 30 days of your suspension/revocation, we will send you a letter asking that you provide proof of in- surance at that time. This letter will list acceptable documents and what will be needed if you do not own a vehicle registered in Pennsylvania. IMPORTANT: Please make sure that PennDOT is notified if you move from your current address. You may notify PennDOT of your addret"s-- change -by calling any of the phone numbers listed at the end of this letter. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, MAY Olt 2009, of this letter. If you file an appeal in the County Court, the Court will give you a time-stamped certified copy of the appeal. In order for your appeal to be valid, you must send this time-stamped certified copy of the appeal by certified mail to: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor? Riverfront Office Center Harrisburg, PA 17104-2516 \\ A (( 091146116265893 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. Sincerely. 9?-U? zgvy.) Janet L. Dolan, Director Bureau of Driver Licensing INFOR ATION 8:00 a.m. to 6300 p.m._ IN STATE 1-800-932-4600 TAD IN STATE 1-800-228-0676 OUT-OF-STATE 717-412-5300 TDD OUT-OF-STATE 717-412-5380 WEB SITE ADDRESS www.dmv.atate.aa.us 4 ADR. 0.2F-1P9 AL Z& Ah 1w C7: 29P "I SFSH LPW FIF.hI IN THE COURT OF COMMON PLWWt COUNTY OF .............. BLATR .........,..»...... .. Nvtlce of Appeal from Summary Crlrnlnal Conv/cticn ?J Name and Address M DefaRdant: Julie E. Rice . 6 Shenandoah court Mechanicsburg, PA 17050 ........ ....... .................. ZI>'..r....,..,....,.,....,........ Date........' .:j..p„1 .,. Issuing Authority Docket No.. NTM49-,o9 .. .......,., ... Citation No......... ?6506679 ......,,. ..................»...........,............,...... Magisterial District No....... 24.1-0 ............... . ............... Appeal from sentence of......... . , ..? .„- 0----' ,•...,....._,».,... , .,.......................•. ,,..•........,.•.. ...........................................,.............:,........»........ Date ofSentence: .. ?!,?Q¢?2009,, ,,, Offense(s) of Webconvictad.,Violation of Secticio 6308(x) of the Crimea Code .................................... w......., .............»........... w..................... .....................................................»......... ».........» Now and malting address dl afflaru as shown on citstlan or cotnpl.Int.......... Officaro Boder~& Cohn Paan State Police Department; .Alt-oaaa,» Cktawas ..............»..r........».......,....•............ r............ . Altoona, $A 16601 ...........................................•..... Name and addreae of leauing.suthorhy: ........... _.............. 613 4th Street ......... ........... ....,................... ............ _...........................r ............. Altoona, PA 16602 .................. ......... _........ ................................... ...ZIP ................. ?? ,,.»94z-6421 It Q It If Sentence Includes fine and ceatR, amount of whiM paid: ..._ .... ...................................................•..,...,_.....,..........,........_..:.....».......... Type or anwunt of bail fumistxd to issuing sutfterity, if any: Aron e n............• .•..........• •....•_._.............................................. ............................ _ NAM and add of Attorney for ahwQ. {aignaturel.. ... . (print (str"q..170.1.1ifth„Ave,,, ,. ... .. ........Phorto946-4316 .._ ........... (addreeP}....,F44?l.a..,Ar .............._.............,.. zIP....16Bp?,. V3100 416 CI,ZRK OP COURT DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON COMMONWEALTH OF PA, : PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS NO. JULIE RICE, Petitioner CERTIFICATE OF SERVICE I hereby certify that on this date a true and exact copy of the foregoing Petition for Appeal from License Suspension was sent to the following address by United States Mail, certified, return receipt requested: DEPARTMENT OF TRANSPORTATION Office of Chief Counsel Third Floor, River Front Office Center Harrisburg, PA 17104 &. V 011 -1V Date: f V Iv- Respectfully submitted, ABELN LAW OFFICES aV4 ?? Shelly S or Legal Assistant 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 FLE&CFACE O .y f 2M9 APR 30 FN 2.47 ?G 1 n v ?? (N-76 r?111_ MAY 0 4 2009 DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON COMMONWEALTH OF PA, : PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS NO. JULIE RICE, Petitioner ORDER AND NOW, this 64 day of . 2009, upon consideration of the within Petition for Appeal from License Suspension, a hearing is set for the 4k day of amaed- , 2009, at o'clock ?.m. in Courtroom No. of the Cumberland County Courthouse. FURTHERMORE, the motor vehicle license suspension in this case is stayed pending the disposition of the appeal hearing \ Cc: George Kabusk, Esquire ;4?'o-r the Commonwealth fegory Barton Abeln, Esquire 419 For the Appellant 4 CW) L4 COL t © Q1 4 ? ? DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON COMMONWEALTH OF PA, : PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS NO. JULIE RICE, Petitioner PETITION FOR APPEAL OF LICENSE SUSPENSION TO THE HONORABLE, THE JUDGE OF THE SAID COURT: AND NOW, comes Petitioner, Julie Rice, by and through her attorney, Gregory Barton Abeln, Esquire, who files the following petition and represents as follows: 1. The Petitioner, Julie Rice is an adult currently residing at 6 Shenandoah Court, Mechanicsburg, PA 17050. 2. Petitioner is the holder of a valid Pennsylvania Operator's License No. 286399914. 3. The Petitioner's has received a notice of license suspension wherein her license is to be suspended as a result of a violation on February 6, 2009 of violating §6308 (offenses related to alcohol). Attachment "A". 4. The Petitioner has filed an appeal with the Blair County Court of Common Pleas, a copy of which is attached to this petition. Attachment "B" 5. Concurrent with the appeal, Appellant has sent to Penn DOT a request for delay of suspension pursuant to 75 P.S. § 1555. 10 WHEREFORE, Appellant requests this Honorable Court to set a time for a hearing on the priority of Appellant's license suspension and immediately stay the imposition of his license suspension pending the result of said hearing. Respectfully Submitted, ABELN LAW OFFI ES DATE: 30 Gregory Barton Abeln, Esquire ID # 35960 Attorney for Appellant 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: MAY O1, 2009 JULIE RICE WID • 091146116265893 001 6 SHENANDOAH CT. PROCESSING DATE 04/24/2009 DRIVER LICENSE # 28639914 MECHANICSBURG PA 17050 DATE OF BIRTH 12/04/1989 LICENSE IN BUREAU Dear MR. RICE: As a result of your violation on 02/06/2009 of violating Section 6308 (offenses related to alcohol), your driving privilege is being SUSPENDED for a period of I YEAR(S) as mandated by section 1532D of the vehicle code. The effective date of suspension is 05/01i2009, 12:01 a.m. This suspension is in addition to any other suspensions al- ready on your record. PROVIDING PROOF OF INSURANCE Within the last 30 days of your suspension/revocation, we will send you a letter asking that you provide proof of in- surance at that time. This letter will list acceptable documents and what will be needed if you do not own a vehicle registered in Pennsylvania. IMPORTANT: Please make sure that PennDOT is notified if You move from your current address. You may notify PennDOT of your 'addrea"s- charge - by callfrig any -of the phone numbers listed at the end of this letter. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, MAY O1, 2009, of this letter. If you file an appeal in the County Court, the Court will give you a time-stamped certified copy of the appeal. In order for your appeal to be valid, you must send this time-stamped certified copy of the appeal by certified mail tot Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 091146116265893 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. Sincerely, 9?u? Z g 04 0 Janet L. Dolan, Director Bureau of Driver Licensing INFORNATION 8:00 a.m. to 6:00 P.M. IN STATE 1-800-932-4600 TDD IN STATE 1-800-228-0676 OUT-OF-STATE 717-412-5300 TDD OUT-OF-STATE 717-412-5380 WEB SITE ADDRESS www.dmy.state.aa.us APR . 3F_t. 2E?09 2:29PM SFSH LAW FIRM _._ . -_. N 7?0 F, IN THIN COURT OF COMMON P LE", COUNTY OF ............ .. BLATR ,, NOV00 Of Appt*aE Morn Summary COMI,711 11 (? ?? Convlct?o?r Name and Address of ovendar,t: Julie E. Rice ................................. .... ............... ,,,.................. .... ,..,..................... 6 8h®naadoah Court Mechanicsburg, PA ,r 17050' . ........ ............................. .......... _...,,,..........,,,. ZIP, .....,..,.... ,,.,............. Date.........: j..../...,. Issuing Authority Docket No.,11?T-152;-09 ..... ......... Citation No.»...... P09ff 7.9 .............. . ..... Magisterial District No... ,, 24- 1-03 ..................... Appeal from sentence of.,.,..... Date ofSantenoe:.,Q,(.Q¢l200?............ Otter?se(s)ofwhich convicted..Violation of Sectiozt 68.'. , _ ..,................ ........ , 3...... ?a`,).,,°fi the.,,Crimes Code ............ Noma ........ ............. ................. ..._,..,........ ,............. I'll ...................... ..........».....,....,...,,.,,...,............,... ......., .,,.......... W mailing address dl atnant as shown on station Ft lUdes fine and rbsbe, amount of which paid: or *DM*lnt........ • Officers Binder 6 Cohn „ Penn State Police..... _ . ............. ......,.. ...,.................. . .................. ............. ...,...... .................. AaparttnQnt of tarn fumistted to issuing acdhnrity, ;f any; Altoona, PA 16601 f ................. .......... ?.»..,,.,..,.._........... 1 1. i ...........,.,,,._..,....,,,, .................................. Nartw and address of faouing.authority: .,.,JR11zli -Aaksz._........................ 615 4th Street ........ .......................... ...................._ ... Altoona. PA 16602 Ikons,...942-6421.................................. xIP,............,.. ,,..... .............. It Q -I Nanw and Aftorrey tar (aignature)„, (print rr,,. ....... (atrget),»x701 Bifth„Ave;W .. Phorts94Er4316 (more")..7,?4Qngt,..?'A .. 16802 , . ,,,.. _............ .YIP ... ..,.. ...,...... ?O?C 113 CL 2RK OF couRT v DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON COMMONWEALTH OF PA, : PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS JULIE RICE, NO. Petitioner : CERTIFICATE OF SERVICE I hereby certify that on this date a true and exact copy of the foregoing Petition for Appeal from License Suspension was sent to the following address by United States Mail, certified, return receipt requested: DEPARTMENT OF TRANSPORTATION Office of Chief Counsel Third Floor, River Front Office Center Harrisburg, PA 17104 W OU U"/ I/ Respectfully submitted, AA'. L '4 -lMq Date: ABELN LAW OFFICES av 4 4?14? Shelly S or Legal Assistant 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 uFI! N? R 0, F ? 1- 1 rT42 3A?R 30 F 3: 4'1 hey a; ws0s 6 L DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PA, VS JULIE RICE, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO.: 09-2726 PETITION FOR CONTINUANCE OF APPEAL OF LICENSE SUSPENSION TO THE HONORABLE, THE JUDGE OF THE SAID COURT: AND NOW, comes Petitioner, Julie Rice, by and through her attorney, Gregory Barton Abeln, Esquire, who files the following petition and represents as follows: 1. The Petitioner, Julie Rice has filed an appeal of her license suspension which was issued from Penn DOT as a result of a violation on February 6, 2009 of 18 P.S§ 6308, Under Age Drinking. 2. The Petitioner has filed an appeal with the Blair County Court of Common Pleas, appealing her summary conviction of Under Age Drinking. 3. T his Honorable Court set August 6, 2009 at 8:46 a.m. as a time and place for her license suspension appeal. 4. The hearing on the underlying charges in Blair County has now been set for August 7, 2009. 5. Petitioner requests that her license suspension hearing be held after the disposition of her underlying charges on August 7, 2009. WHEREFORE, Petitioner requests that the hearing on her license suspension set for August 6, 2009 be continued for at least 45 days to allow a disposition to be reach on her appeal of the underlying offense of Under Age Drinking. DATE: Respectfully Submitted, ABELN LAW O IC -Qjs Greg y arton Abeln, Esquire ID 435960 Attorney for Appellant 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PA, VS JULIE RICE, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO.: 09-2726 CERTIFICATE OF SERVICE I hereby certify that on this date a true and exact copy of the foregoing Petition for Appeal from License Suspension was sent to the following address by United States Mail, certified, return receipt requested: DEPARTMENT OF TRANSPORTATION Office of Chief Counsel Third Floor, River Front Office Center Harrisburg, PA 17104 _?Jlq / Date: d Respectfully submitted, ABELN LAW OFFICES lfk Shelly dnor Legal Assistant 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 FILFD--O? FCE OF THc PRO"?'C700TARY 2009 JUN 10 PM 1: 13 D JUN 1 12009G? DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PA, VS JULIE RICE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO.: 09-2726 Petitioner ORDER AND NOW, this KI day of , 2009, upon the I within Petition for Continuance of a hearing on the Appeal from License Suspension, said 2009, at q5 o'clock a-.m. in Courtroom No. 2 of the Petition is GRANTED. A hearing is now set for the 7 6A day of Cumberland County Courthouse. Cc: nn DOT For the Commonwealth ,,?Gregory Barton Abeln, Esquire For the Appellant l?D?tE.S r»?cl?c?. 4P -v FILED-- ),l-F;CE OF THE FDOT -IrN")TARY 2009 JUN' 16 PM 3: 42 C t r" JAN ~' S `ll~ln G~ DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PA, JULIE RICE, VS Petitioner ORDER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO.: 09-2726 AND NOW, this ~~ ~' day of , 2009, upon the within Petition for Continuance of a hearing on the Appeal from License Suspension, said Petition is GRANTED. A hearing is now set for the ~ # day of _~`_I_` , 2010, at II:OD o'clock Get .m. in Courtroom No. 5 of the Cumberland County Courthouse. By the Court, Albert H. Maslan , J. ~ ~ Penn DOT Cc: For the Commonwealth /e or Barton Abeln Es uire g Y q n c~- ' ;-a For the Appellant ~ ;°~, c_ --, - " =`~; ,~ -n ~ ~ ` ~a ~ ~ Es rn~c l£d., ~ ~, nz c~, ~ ~ .,-~; ,-, -r 7 ` _ _ Ufa?~ia ~~- ~~ ~;`r .~ `rl =' ~ -=